OT:RR:NC:N2:206
Oscar Palacios
C.H. Robinson International
180 E. Ocean Blvd, Suite 700
Long Beach, CA 90802
RE: The country of origin of a steering wheel
Dear Mr. Palacios:
In your letter dated May 30, 2025, you requested a country of origin ruling for marking purposes on behalf of
your client, TG ASK.
The merchandise under consideration is a Steering Wheel, Part Number GS11084880, which is intended for
use with certain Lexus passenger vehicle models. The steering wheel is made using an aluminum diecast
armature. The base wheel is made of polyurethane (PU) and incorporates heating elements while wrapped in
leather. Once imported into the United States, a bezel will be added to complete the finished steering wheel.
The aluminum diecast armature and PU base is manufactured in the United States and shipped to Mexico for
further assembly. The heating sensor elements and thread of Vietnamese origin, leather from Italy, and wood
elements from Japan are sourced in the United States and shipped to Mexico for use in the production of the
steering wheel assembly. In Mexico, the leather wrap and heating elements are assembled into the PU
wheelbase. The cutting, skiving, sewing of the leather into the steering wheel loop shape is also performed in
Mexico. Once the loop is completed, it is placed around the base wheel and sewed and stitched by hand. The
wood elements are inserted to finalize the steering wheel before being inspected and packaged for export to
United States.
Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every
article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly,
indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to
indicate to the ultimate purchaser in the United States, the English name of the country of origin of the
article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to
know by an inspection of the marking on the imported goods the country of which the goods is the product.
The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by
knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940).
Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of
manufacture, production, or growth of any article of foreign origin entering the United States. Further work
or material added to an article in another country must effect a substantial transformation in order to render
such other country the “country of origin” within the meaning of the marking laws and regulations.
Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other
USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in
sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect
to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining
the country of origin of a good for marking purposes, with the exception of textile and apparel goods which
are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11.
Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in
which:
(1) The good is wholly obtained or produced;
(2) The good is produced exclusively from domestic materials; or
(3) Each foreign material incorporated in that good undergoes an applicable change in tariff
classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and
all other applicable requirements of these rules are satisfied.
The wheel is neither wholly obtained or produced ” entirely in a USMCA country or produced entirely in a
USMCA country from originating materials per GN 11(b)(i) and (b)(ii). Therefore, we must next determine
whether the non-originating materials undergo the tariff shift and satisfy the applicable requirements of GN
11(b)(iii) and GN 11(b)(o). The wheel is classified under subheading 8708.94, Harmonized Tariff Schedule
of the United States (HTSUS). The tariff shift requirement in Part 102.20 for the wheel at issue states:
A change to parts for steering systems of tractors suitable for agricultural use, parts for steering
systems of other tractors (except road tractors), parts of cast-iron or to other parts for steering systems
from any other good of subheading 8708.94 or from any other subheading, except from parts or
accessories of the goods of subheading 8708.40, 8708.50, 8708.80, 8708.91, 8708.92, or 8708.95
through 8708.99; or
A change to any other good of subheading 8708.94 from parts for steering systems of tractors suitable
for agricultural use, parts for steering systems of other tractors (except road tractors), parts of
cast-iron or from other parts for steering systems of subheading 8708.94, except when the change is
pursuant to General Rule of Interpretation 2(a), or from any other subheading, except from parts or
accessories of the goods of subheading 8708.40, 8708.50, 8708.80, 8708.91, 8708.92, or 8708.95
through 8708.99, when that change is pursuant to General Rule of Interpretation 2(a).
Since the wheel is a steering system and not a part, only the second paragraph applies. Here, the steering
system is classifiable in subheading 8708.94 and the parts (diecast armature, wheel base, heating elements,
and bezel) are classified in other headings. Therefore, the tariff shift is met and the country of origin of the
steering wheel, Part Number GS11084880, is Mexico. The goods can be marked as “Made in Mexico” or
“Product of Mexico.”
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents
filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact
National Import Specialist Liana Alvarez at [email protected].
Sincerely,
James Forkan
Acting Director
National Commodity Specialist Division